IR 07200028/2022001
| ML22307A243 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/15/2022 |
| From: | Anthony Dimitriadis Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Berryman B Susquehanna |
| References | |
| IR 2022001 | |
| Download: ML22307A243 (1) | |
Text
December 15, 2022
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION - INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) NRC INSPECTION REPORT NO.
07200028/2022001
Dear Mr. Berryman:
On October 21, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the Susquehanna Steam Electric Station (Susquehanna) Independent Spent Fuel Storage Installation (ISFSI) activities. On-site inspections were performed on July 26 - 27, 2022, September 13 - 14, 2022, September 21 - 22, 2022, and October 3 - 5, 2022. The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and the conditions of your license and the Certificate of Compliance (CoC). The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records and plant walk-downs. The results of this inspection were discussed with Kevin Cimorelli, Site Vice-President, and other members of your staff on October 20, 2022, and are documented in the enclosed report.
No violations of safety significance were identified during this inspection.
In accordance with Title 10 of The Code of Federal Regulations (10 CFR) 2.390 of the NRC's
"Rules of Practice," a copy of this letter and its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. Current NRC regulations and guidance are included on the NRC's Web site at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).
No reply to this letter is required. Please contact Mark Henrion of my staff at 610-337-6968 if you have any questions regarding this matter.
Sincerely, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security Docket No:
07200028 License No:
Enclosure:
Inspection Report
07200028/2022001 w/Attachment: Supplemental Information
REGION I==
Inspection Report
Docket No:
072-00028
License Nos:
Report No:
07200028/2022001
Licensee:
Susquehanna Nuclear, LLC
Facility:
Susquehanna Steam Electric Station
Location:
Berwick, PA
Dates:
July 26, 2022 - October 21, 2022
Inspectors:
E. Andrews, Technical Assistant C. Hargest, Health Physicist (Training)
M. Henrion, Health Physicist P. Koch, Structural Engineer T. Liu, Senior Project Manager E. Love, Transportation and Storage Safety Inspector O. Masnyk Bailey, Health Physicist J. Woodfield, Transportation and Storage Safety Inspector
Approved by:
Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Enclosure
EXECUTIVE SUMMARY
Susquehanna Nuclear, LLC
Susquehanna Steam Electric Station NRC Inspection Report No. 07200028/2022001
On October 21, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a period of on-site inspections of Susquehannas Independent Spent Fuel Storage Installation (ISFSI)activities. On-site inspections were performed of dry run operations for welding and non-destructive examinations on July 26 - 27, 2022, for spent fuel pool operations on September 13 - 14, 2022, for canister processing on September 21 - 22, 2022, and for transportation operations on October 3 - 5, 2022. An on-site inspection of the Holtec dry cask loading at Susquehanna was performed on October 17 - 21, 2022. The inspections consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs. The NRCs program for overseeing the safe operation of dry storage of spent fuel at an ISFSI is described in Inspection Manual Chapter 2690, Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations and for 10 Code of Federal Regulations (CFR) Part 71 Transportation Packagings.
No violations of more than minor safety significance were identified during this inspection.
REPORT DETAILS
1.0 Independent Spent Fuel Storage Installation
1.1 Background
Susquehanna Steam Electric Station (Susquehanna), selected Holtec HI-STORM FW Cask System technology to allow spent nuclear fuel assemblies currently stored at Susquehannas spent fuel pool (SFP) to be relocated and stored using an ISFSI. The Holtec system is listed in 10 CFR 72.214, List of Approved Spent Fuel Storage Casks, under Certificate of Compliance (CoC) No. 1032. Holtec updated Final Safety Analysis Report (FSAR), Revision 8, applies to the Holtec ISFSI system that was placed in service under CoC number 1032.
1.2 Onsite Fabrication of Components and Construction of an ISFSI (IP 60853)
a. Inspection Scope
The ISFSI pads located at Susquehanna were designed and constructed to store TN NUHOMS Horizontal Storage Modules (HSMs) on five separate pad foundations. At the time of this inspection, 121 casks were stored in NUHOMS HSMs and placed on the Susquehanna ISFSI pads. Susquehanna plans to load up to 26 HI-STORM FW units on the remainder of the existing storage pads. The inspectors reviewed the evaluations to ensure a demonstration of reasonable assurance that the ISFSI pad at Susquehanna complies with the requirements of 10 CFR 72.212(b)(5)(ii). The inspectors performed a review of the structural assessment of the ISFSI pad design review for static and dynamic loads associated with the new casks, as required by 10 CFR 72.212. In addition, the inspectors reviewed the tip over analysis of the HI-STORM FW storage cask and the soil structure interaction analysis performed for Susquehanna. The inspectors focused their review on completeness and accuracy of the information provided by the licensee and evaluated the analysis and design methodology used for the additional HI-STORM casks on the Susquehanna ISFSI pad to determine if it was consistent with the HI-STORM FW FSAR as well as applicable guidance in American Concrete Institute (ACI) 318, ACI 349, NUREG-1536, NUREG-2215 and NUREG-0800. The staff concluded that Susquehannas overall approach was reasonable, satisfied the requirements of 10 CFR 72.212(b)(5)(ii),and therefore provides a reasonable assurance of safety.
b. Findings
No violations of more than minor significance were identified.
1.3 Pre-operational Testing of an ISFSI (IP 60854)
a. Inspection Scope
The inspectors evaluated Susquehannas performance during NRC observed pre-operational (dry run) activities that were performed in order to fulfill requirements in the NRC-issued CoC No. 1032, Amendment 5 (CoC 1032-A5). The inspectors observed the licensees dry run activities related to welding and non-destructive examinations on July 26 - 27, 2022, spent fuel pool operations on September 14 - 15, 2022, canister processing on September 21 - 22, 2022, and transportation operations on October 3 - 5, 2022.
During the dry run activities, the inspectors observed cask loading, welding, processing, and movement activities to determine whether the licensee had developed the capability to properly load, process and move the multi-purpose canister (MPC) to be used in storage of spent fuel at Susquehanna. The inspectors observed:
- (a) movement of a dummy fuel assembly into the MPC;
- (b) movement of the MPC/HI-TRAC from the fuel pool to the Cask Processing Area;
- (c) closure welding of a MPC mockup;
- (d) non-destructive weld examinations;
- (e) hydrostatic testing;
- (f) forced helium dehydration;
- (g) blowdowns;
- (h) simulated radiological field survey activities;
- (i) stack-up and transfer of the MPC from the HI-TRAC to the HI-STORM;
- (j) retrieval of the MPC from the HI-STORM and movement back into the HI-TRAC;
- (k) installation of the HI-STORM lid; and
- (l) transport of the HI-STORM on the HI-PORT from the reactor building truck bay to the ISFSI pad area.
The inspectors attended select site pre-job briefings to assess Susquehannas ability to identify critical steps of the evolution, potential failure scenarios, and human performance tools to prevent errors. The inspectors reviewed the training program and training records of personnel assigned to ISFSI activities. Additionally, the inspectors reviewed MPC loading, unloading, and processing procedures to determine if they contained commitments and requirements specified in the CoC, technical specifications (TSs), FSAR, and Title 10 of the CFR Part 72. The inspectors also reviewed Susquehannas fuel selection procedures to ensure they appropriately incorporated the requirements in the TSs.
The inspectors reviewed radiation protection procedures and radiation work permits associated with the proposed ISFSI loading campaign. The inspectors also reviewed the radiological controls which would be established during an MPC loading campaign and also reviewed corrective action reports associated with preparations for the ISFSI loading campaign to ensure that issues were being properly identified, prioritized, and evaluated commensurate with their safety significance.
b. Findings
No violations of more than minor significance were identified.
1.4 Operation of an ISFSI at Operating Plants (IP 60855)
a. Inspection Scope
From October 17 - 21, 2022, the inspectors observed and evaluated Susquehannas loading of the second MPC associated with its initial Holtec HI-STORM FW Cask System dry cask campaign on-site at Susquehanna. The inspectors also reviewed the licensees activities associated with long-term operation and monitoring of the ISFSI.
The inspectors evaluated compliance with the CoC, TSs, and station procedures.
The inspectors observed fuel assemblies being loaded into the MPC, processing operations including welding, non-destructive weld examinations, hydrostatic testing, vacuum drying, helium backfill, and survey activities. The inspectors also observed movement activities including stack-up, vertical cask transporter (VCT) operations, and placement of the HI-STORM at its final location on the pad. During performance of these activities, the inspectors verified that procedure use, communication, and coordination of ISFSI activities met established licensee standards and requirements.
The inspectors reviewed Susquehannas program associated with fuel characterization and selection for storage and reviewed the second cask fuel selection package to determine if the licensee was loading fuel in accordance with the CoC, TSs, and procedures. Inspectors reviewed a recording made of the fuel assemblies loaded into the second MPC to determine if the loading was in accordance with Susquehannas loading plan.
The inspectors observed radiation protection surveys and job coverage for the cask loading workers, and reviewed survey data maps and radiological records from the second MPC loading to determine if radiation survey levels measured were within limits specified by the TSs and consistent with values specified in the FSAR.
The inspectors reviewed corrective action reports and the associated follow-up actions that were generated since Susquehannas dry run demonstrations, to determine if issues were entered into the corrective action program (CAP), prioritized, and evaluated commensurate with their safety significance.
b. Findings
No violations of more than minor significance were identified
1.5 Review of 10 CFR 72.212
- (b) Evaluations (IP 60856)
a. Inspection Scope
Susquehanna is utilizing the Holtec International HI-STORM FW Cask System for the storage of spent fuel at the onsite ISFSI. The HI-STORM FW casks augment the Standardized NUHOMS casks already in service at the current ISFSI, which began operation in 1999.
The review of the HI-STORM FW Cask System was based on NRC-issued CoC 1032-A5 and its associated Safety Evaluation Report (SER), and HI-STORM FW FSAR Revision 8.
The review of the Part 50 facility site-specific parameters utilized the UFSAR, and other applicable plant-specific design and licensing basis information.
The inspectors evaluated the licensees compliance with the requirements of 10 CFR 72.212. The inspectors examined Susquehannas written evaluations to determine if they were in accordance with 10 CFR 72.212(b)(5) and evaluated the conditions set forth in the CoC to determine if conditions had been met prior to use and if the radiological requirements outlined in 10 CFR 72.104 were met. The inspectors examined applicable reactor site parameters, such as hypothetical fire and explosions, tornadoes, wind-generated missile impacts, seismic qualifications, lightning, flooding and temperature, to determine if they had been evaluated for acceptability with bounding values specified in the FSAR and the NRC SER. The inspectors also examined 50.59 evaluations related to the construction and operation of the ISFSI and plant interfaces to determine if they were performed and to determine if changes to certain facility design bases and FSAR commitments required prior NRC approval. The reactor emergency plan, quality assurance program, training program, and radiation protection program were reviewed to determine if there was a decrease in effectiveness and if changes made required prior NRC approval.
b. Findings
No violations of more than minor significance were identified.
2.0 Exit Meeting
On October 20, 2022, the inspectors presented the inspection results to Kevin Cimorelli, Site Vice-President, and other members of the Susquehanna staff who acknowledged the inspection results. No proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
- K. Cimorelli, Site Vice-President
- A. Nestico, Dry Fuel Storage Project Manager
ITEMS OPENED, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
CFR 50.59 and 10 CFR 72.48 Screenings/Evaluations
50.59 Screen Number 50.59 SD 02455, Revision 0
2.48 Screen Number 72.48 SD 00131, Revision 0
2.48 Screen/Evaluation Number 72.48 SE 00002, Revision 0
Calculations
EC-012-2842, Storage of Cask Pool Plugs in the Dryer/Separator Pit, Revision 0
EC-012-6032, Independent Spent Fuel Storage Installation and OEM Steam Dryer Storage
Installation - Laydown Transport Analysis, Revision 12
EC-012-6131, SSES Haul Path Evaluation - Reactor Building to ISFSI, Revision 0
EC-012-6132, Structural Evaluation of the Dryer Separator Pit Floor Slab and Stability Analysis of
the HI-TRAC VW at SSES, Revision 0
EC-012-6133, Structural Evaluation of the Cask Storage Pit Floor Slab and Stability Analysis of
the HI-TRAC VW at SSES, Revision 0
EC-012-6134, Empty MPC-89 Stability Analysis at SSES, Revision 0
EC-034-1039, Thermal Evaluation of HI-TRAC VW in Dryer-Separator Pit Area at Susquehanna
NPP, Revision 0
EC-034-1040, Cask Spacing Thermal Analysis for HI-STORM Transition at SSES, Revision 0
EC-034-1041, Thermal Evaluation of HI-STORM FW Version E Fire at Susquehanna NPP, Revision 0
EC-089-1014, Evaluation of Plant Hazards at SSES, Revision 0
EC-089-1017, RRTI-3032-0009 - HI-STORM in Icing Conditions, Revision 0
EC-ENVR-1025, Fuel Cycle 40CFR190 Dose Calculation, Revision 9
EC-ENVR-1067, Susquehanna Steam Electric Station Site Boundary Dose Rates Evaluations for
HI-STORM FW System, Revision 0
EC-FLOD-1002, Impact of Postulated Flooding from Rupture of Cooling Tower Basin, Circulating
Water in Turbine Building, U1&2 CSTs and RWST, Revision 2
EC-FUEL-1941, Fuel Loading Plan Report for Susquehanna Steam Electric Station, Revision 0
EC-HVLD-1043, Cask Handling Weights at Susquehanna Steam Electric Station, Revision 0
EC-HVLD-1044, Structural Analysis of HI-TRAC VW Lift Yoke for Susquehanna Steam Electric
Station, Revision 0
EC-HVLD-1046, Swaying Analysis of the HI-TRAC VW in Reactor Building at SSES, Revision 0
EC-HVLD-1047, Blast Effect Evaluation of HI-STORM & HI-PORT at Susquehanna Steam Electric
Station, Revision 0
EC-HVLD-1048, Structural Evaluation of the Refuel Floor Slab and Stability Analysis of the HI-TRAC
VW at SSES, Revision 0
EC-HVLD-1049, Seismic Stability Analysis of HI-STORM on HI-PORT at SSES, Revision 0
EC-RADN-1186, HI-STORM FW and HI-TRAC VW CoC Radiation Protection Program Dose
Rate Limits for SSES, Revision 0
EC-RADN-1188, ISFSI Radiation Shield Wall for Susquehanna Steam Electric Station, Revision 0
EC-STRU-1037, NUHOMS ISFSI Pad Foundation Seismic Analysis, Revision 6
EC-STRU-2128, Seismic Analysis of Existing ISFSI Pads (Basemats) at Susquehanna Steam
Electric Station (SSES), Revision 0
EC-STRU-2129, Structural Analysis of the Non-Mechanistic Tip-Over Event of the Loaded
HI-STORM FW Version E Storage Cask at SSES, Revision 0
EC-STRU-2130, Stability/Structural Qualification of VCT Under Seismic Loads at SSES, Revision 0
EC-STRU-2131, Seismic Stability Analysis of HI-STORM/HI-TRAC/HI-PORT Stack-up During
MPC Transfer Operations, Revision 0
EC-STRU-2133, RRTI-3032-001 - SSES Site Specific Tornado Missiles Analysis, Revision 0
EC-STRU-2135, Structural Analysis of the SSES Rail Bay Floor During the MPC Loading
Operations, Revision 0
EC-STRU-2137, Stability Analysis of the HI-STORM on HI-PORT under Tornado Missiles Impact
at SSES, Revision 0
EC-STRU-2138, Analysis of a Postulated Tower Collapse Accident at Susquehanna Steam
Electric Station (SSES), Revision 0
EC-STRU-2139, Stability Analysis of the HI-TRAC Inside the SSES Reactor Building Under
Tornado Missile Impacts, Revision 0
Corrective Action Issue Reports (IRs)
CR-2022-09020
CR-2022-11516
CR-2022-12957
CR-2022-13801
Miscellaneous
CFR 72.212 CoC 1004 Evaluation Report for the Standardized NUHOMS, Revision 14
CFR 72.212 CoC 1032 Evaluation Report for the HI-STORM FW MPC Storage System,
Revision 0 (LDCN 5642 and LDCN 5718)
Certificate of Compliance 1032 Amendment 5, Revision 0
Drawing D220819 Sheet 21, SSES Reactor Building Unit 1 & 2 Safe Load Paths for the
Spent Fuel Dry Storage Process Components, Revision IDCN3
Drawing D246232, SSES Site Plan - Access for Spent Fuel Dry Storage Process Components,
Revision IDCN2
Drawing E105002, Site Arrangement, Revision 18
Drawing FF61945 Sheets 317 through 324, 361, and 362, SSES General Arrangement Drawing
for Dry Storage Equipment, Revision (all) IDCN1
Drawing FF61945, Sheet 230, ISFSI Pad Expansion Plan, Revision 2
Drawing FF61945, Sheet 231, ISFSI Pad Expansion Details, Revision 1
Drawing FF61945, Sheet 355 and 376, Concrete Shield Wall Details, Revision (all) IDCN1
Drawing FF61945, Sheet 91C, NUHOMS ISFSI HSM Placement, Revision IDCN5
Drawing FF61945, Sheets 350, 351, 363, and 377, SSES Existing ISFSI General Arrangement,
Revision (all) IDCN1
Drawing FF61945, Sheets 353, 354, and 378, SSES Heavy Haul Path, Revision (all) IDCN1
Fire Protection Program Screen FPSD 00194, Revision 0
FSAR HI-STORM FW MPC Storage System, Revision 8
Holtec International Purchase Specification PS-3107, Purchase Specification for the HI-STORM
FW Lifting Bracket, Revision 7
Holtec International Purchase Specification PS-3209, Purchase Specification for the MPC Lift Cleats
for the HI-STORM FW System, Revision 7
Holtec International Purchase Specification PS-3702, Procurement Specification for the HI-TRAC
VW Lift Yoke, Revision 10
Report EC 2373129, 50.59 Screening SD 02455, Integration of Holtec Cask Design into Plant
Operation, Revision 0
Susquehanna Steam Electric Station Final Safety Analysis Report
Technical Requirements for Operation (TRO) 3.10.3, Independent Spent Fuel Storage
Installation (ISFSI)
Procedures
EP-RM-004, EAL Classification Bases, Revision 20
ME-0RF-152, Dry Fuel Storage-Response to Crane/Rigging/Transfer Equipment Malfunction
and Certificate of Compliance Technical Specification Requirements, Revision 7
MT-199-001, Reactor Building Crane Operating Procedure, Revision 27
NDAP-QA-0023, SSES Records Management Program, Revision 12
NDAP-QA-0505, Crane, Hoist, and Rigging Process, Revision 48
NDAP-QA-0658, Dry Fuel Storage Program, Revision 19
NDAP-QA-0726, 10 CFR 50.59 and 10 CFR 72.48 Implementation, Revision 24
NDAP-QA-1001, Nuclear Fuel Reliability Program, Revision 17
ODCM-QA-008, Radiological Environmental Monitoring Program, Revision 21
RE-081-043, Selection and Monitoring of Fuel for Dry Storage, Revision 16
RP-002, Radiation and Contamination Surveys, Revision 2
SSES-HPP-3032-0090, Equipment Mobilization and Preparation at SSES, Revision 1
SSES-HPP-3032-100, MPC Pre-Operation Inspection at SSES, Revision 0
SSES-HPP-3032-200, MPC Loading at SSES, Revision 0
SSES-HPP-3032-300, MPC Processing (FHD) at SSES, Revision 0
SSES-HPP-3032-400, MPC Stack-Up and Transfer at SSES, Revision 0
SSES-HPP-3032-500, HI-STORM Operations and Transport at SSES, Revision 0
SSES-HPP-3032-600, MPC Unloading at SSES, Revision 0
SSES-HPP-3032-700, Response to Abnormal Conditions at SSES, Revision 0
SSES-HPP-3032-800, Temperature Monitoring at SSES, Revision 0
SSES-MSLT-MPC-HOLTEC, Helium Mass Spectrometer Leak Test Procedure Multipurpose
Canister, Revision 0
SSES-PI-CNSTR-OP-HLTC-H-01, Closure Welding of Holtec Multi-Purpose Canisters-HI-STORM
100, HI-STAR 100, HI-STORM FW & UMAX Systems, Revision 0
LIST OF ACRONYMS USED
American Concrete Institute
Corrective Action Program
Certificate of Compliance
CoC 1032 - 5R0
Certificate of Compliance 1032, Amendment 5, Revision 0
CFR
Code of Federal Regulations
Final Safety Analysis Report
GPO
Government Printing Office
HSM
Horizontal Storage Module
Independent Spent Fuel Storage Installation
Multipurpose Canister
Non-Cited Violation
NRC
U.S. Nuclear Regulatory Commission
Public Health Emergency
Safety Evaluation Report
Spent Fuel Pool
Susquehanna Steam Electric Station
TS
Technical Specifications
Updated Final Safety Analysis Report
Vertical Cask Transporter